8. ANALYSIS OF IMPORT DATA
8.1 RMS BILLS OF ENTRY:
January, 2017:
I
n this section, the results of the data analysis for the two periods, i.e. January, 2017 and July, 2017 have been pre-sented. The release time for normal bill of entry and advance bills of entry are separately pre-sented. Further, for both nor-mal and advance bills of entry,results in respect of RMS bills of entry, Assessment and Ex-amination (A+E), Assessment only (A) and First Check (FC) are separately presented. With-in the RMS bills of entry, the release time for DPD and non-DPD bills of entry are separate-ly presented.
D
uring the period 1st to 7th January, 2017, a total of 12,816 bills of entry were filed. Out of these, at the time of collection of data, in respect of 385 bills of entry out of charge had either not been given owing to issues relating to infringement of statutory provisions or were given after 30 days after com-pletion of mandatory customs procedures. These 385 bills of entry, accounting for very small percentage of the total bills of entry, have been excluded from the study. Thus, the sample size for January, 2017 is 12,431.Out of the total 12,431 bills of entry, 6,620 bills of entry, ac-counting for 53.2% were filed
as advance bill of entry, while 5,811 bills of entry (46.7%) were filed as normal bill of en-try. Viewed differently, out of the total 12,431 bills of entry, it is observed that 6,893 bills of entry (55.4%) were facilitated by RMS, i.e., the goods were cleared without assessment and examination. Interestingly, out of these RMS facilitated bills of entry, only 3,452 bills of entry (27.7%) were advance bills of entry and almost similar number of 3,441 (27.6%) were normal bill of entry. This break-up ap-pears to suggest that the RMS facilitation is agnostic to the dis-tinction between advance and normal bill of entry.
July, 2017:
The cargo release time, cal-culated from grant of entry in-wards to out of charge for RMS
facilitated bills of entry for Janu-ary, 2017 is tabulated below:
(In hours) S. No. Type of Bill
of Entry RMS Overall RMS-DPD RMS-Non DPD
(1) (2) (3) (4)
1 Normal 183.60 167.52 196.39
2 Advance 96.24 76.08 112.82
3 Total 139.85 121.04 155.04
Note: Column 2 represents the weighted average of column 3 and 4.
Row 3 represents the weighted average of row 1 and 2.
D
uring the period 1st to 7th July, 2017, a total of 14,629 bills of entry were filed. Out of these, there are 276 bills of entry where out of charge has either not been given due to contravention of the statutory provisions or giv-en after 30 days, subsequgiv-ent to the completion of mandatory procedures. These bills of en-try have been excluded from the scope of the study. Thus, the representative sample size for July, 2017 is 14,353. Out of these 14,353 bills of entry filed, 5,339 (37.1%) were advancebills of entry and remaining 9014 bills of entry (62.8%) nor-mal bills of entry.
It is important to note that despite the roll out of GST with effect from 1st July, the total number of bills of entry filed during the sample period in July, 2017 was 14.1% higher than in January, 2017. In fact, part of the spurt could be on ac-count of reluctance on the part of the importers to file advance bills of entry in the preceding week, given the uncertainties associated with GST roll out.
The increase in the total bills of
entry ties up well with the ex-pected decline in the number and percentage of advance bills of entry filed during July, 2017 vis-a-vis January, 2017.
Viewed differently, out of the total 14,353 bills of entry filed during the period, 51.5% of the bills of entry, numbering 7,396 were facilitated by RMS. Out of
these RMS facilitated bills of en-try, 3,093 bills of entry (21.5%) were advance and remaining 4,303 (29.9%) were normal bills of entry.
The cargo release time, cal-culated from grant of entry in-wards to out of charge for RMS facilitated bills of entry for July, 2017 is tabulated below:
(In hours) S. No. Type of
Bill of Entry RMS
Overall RMS-DPD RMS-Non DPD
(1) (2) (3) (4)
1 Normal 164.88 140.4 185.52
2 Advance 98.88 75.36 129.36
3 Total 137.28 109.88 164.94
Note: Column 2 represents the weighted average of column 3 and 4.
Row 3 represents the weighted average of row 1 and 2.
A comparison of the over-all release time for RMS bills of entry shows a marginal im-provement from 139.85 hours to 137.28 hours from January to July, 2017. This improvement has been on account of reduc-tion in the release time of nor-mal bills of entry, which has im-proved significantly from 183.60 hours to 164.88 hours, with the release time of advance bills of
entry showing a slight increase from 96.24 hours to 98.88 hours.
It is felt that the decline in the share of advance bills of entry, with significantly lower release time vis-à-vis normal bill of en-try, has resulted in an increase in the weighted average release time for overall RMS bills of en-try in the month of July, 2017 over January, 2017. It is inter-esting to note that the release
time for advance DPD bills of entry, which represents the best category of bills of entry from the release time perspective, have stagnated at around 76 hours. Given the guidelines per-taining to DPD clearances with-in 48 hours, it is seen that there is significant scope for further reduction in the release time of DPD cargo.
In respect of RMS bills of entry, it is seen that 2092 bills of entry (January) and 2049 bills of entry (July) have been given out of charge within 72 hours, which is 16.8% and 14.2% of the sample size for the respec-tive months. For DPD importers having RMS facilitated bills of
entry, 1261 (10.1%) and 1501 (10.4%) have been given out of charge within 72 hours in Janu-ary and July of 2017 respective-ly. More importantly, out of the advance bills of entry filed by DPD importers and facilitated by the RMS, it is observed that 59.4% (927 bills of entry) and 61.7% (1074 bills of entry) have been released within 72 hours from customs control in January and July, respectively. Thus, it is seen that the commitment made in National Action Plan under TFA to achieve aver-age release time of 3 days for sea ports, is close to being achieved in respect of ad-vance-DPD bills of entry.
January and July 2017 –stage analysis A comparison of the time taken at different stages of time release for normal and advance bills of entry for the two periods
bring out the basic difference between these two categories, highlighting the obvious advan-tage of advance bills of entry.
NORMAL RMS BILLS OF ENTRY
January, 2017 July, 2017
STAGES ROLE Time
(Hrs) Percentage
time taken Time
(Hrs) Percentage time taken INW-SUB IMPORTER/
CHA 98.3 53% 59.5 36%
SUB-ASS CUSTOMS 0.14 0% 0.09 0%
ASS-PAY IMPORTER/
CHA 57.19 31% 67.44 41%
PAY-REG IMPORTER/
CHA 23.38 13% 35.53 22%
REG-OOC CUSTOMS 7.13 4% 2.19 1%
Total Release Time
100% 100%
ADVANCE RMS BILLS OF ENTRY
January, 2017 July, 2017
STAGES ROLE Time
(Hrs) Percentage
time taken Time
(Hrs) Percentage time taken SUB-INW IMPORTER/
CHA -44.52 - -49.42
-SUB-ASS CUSTOMS 0.13 - 0.1
-INW-ASS CUSTOMS -44.39 - -49.32
-ASS-PAY IMPORTER/
CHA 117.74 - 101.01
-INW-PAY IMPORTER/
CHA 73.35 73% 51.69 50%
PAY-REG IMPORTER/
CHA 19.09 19% 49.78 48%
REG-OOC CUSTOMS 8.51 8% 1.77 2%
Total
Re-lease Time 100% 100%
The above analysis shows that in respect of RMS bills of entry, whether advance or nor-mal, the time taken by customs is minimal and has declined further to account for minimal 1-2% of the total release time during July, 2017.
The decline in the time taken by the importer in filing normal bill of entry after entry inwards has been significant from 98.3 hours in January, 2017 to 59.5 hours in July, 2017. This appears to be at-tributable to amendment in the provisions of the Customs Act (Section 46) to prescribe for a late filing fine in case the bill of entry is not filed within the next day after granting of entry inwards to the vessel. Under-standably, holidays are exclud-ed from calculating this time period. The release time com-parison for RMS bills of entry
for the months of January 2017 and July 2017 is shown below.
As mentioned earlier, for the overall RMS facilitated cargo the time release decreased from 139.85 hours to 137.28 hours. It is also seen that in January, 2017, 30.4% of bills of entry were cleared within 72 hours, which is the TFA com-mitment for time clearances of cargo as seaports. However, in July, 2017 the percentage of bills of entry cleared within 72 hours has dropped to 27.7%.
But in absolute terms, a larger number of bills of entry were cleared within 72 hours when compared with January, 2017.
Moreover, an important fact emerging from the distribution curve depicted below is that 90% of RMS facilitated cargo is being cleared in time that is 9% faster in July 2017 as com-pared to January, 2017.
Note: Customs Duty payment is exempt for several commodities and therefore they have not been considered for calculating the average time from assessment to payment and from payment to registration. Secondly, there have been instances where due to re-assessment the duty payment in the system is reflected as being deposited prior to assessment. Such cases also distort the data and have not been considered for arriving at average release time for RMS and all other types of bills of entry mentioned hereinafter. As a result the summation of time taken at each stage, being an average of the process time, will not be equal to the overall release time of cargo from entry inwards to out of charge.
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NCH has continued to push for more clients to opt for and avail DPD. The number of importers eligible for DPD has increased from around 600 in January, 2017 to around 1200 in July, 2017. Accordingly, the num-ber of DPD bills of entry have increased from 3067 during Jan-uary, 2017 to 3721 during July, 2017, showing a growth of 20.4 percent. In view of the special dispensation provided to DPDclients, during January, 2017 the release time for DPD bills of en-try, within the RMS bills of entry was significantly lower at 121.04 hours, as against 155.04 hours for non-DPD bills of entry, show-ing that the release time for DPD bills of entry was 34 hours low-er than non-DPD bills of entry.
Therefore, it shows that the re-lease time for importer improves by more than 1 day by opting for DPD.
8.1.1 DPD BILLS OF ENTRY:
For DPD bills of entry, during January, 2017, the release time for those who filed advance bills of entry was 76.08 hours, whereas it was more than dou-ble at 167.52 hours for normal bills of entry. Clearly, it shows that for reaping the full benefits of DPD in terms of reduction in the release time, it is incumbent on the importers to file advance bills of entry.
The release time for DPD bills of entry improved from 121.04 hours in January, 2017 to 109.88 hours in July, 2017, showing an improvement by 9.22 percent. While the aver-age release time for DPD ad-vance bills of entry remained unchanged at around 76 hours, it improved significantly from 167.52 hours in January, 2017 to 140.44 hours for DPD normal bills of entry. This reduction in the release time for DPD nor-mal bills of entry is attributable to two factors: (a) reduction in the time taken from entry in-wards to submission of bill of entry from 86.45 hours in Janu-ary, 2017 to 55.95 hours in July, 2017, which is influenced by the change in the law to prescribe
imposition of fine in case of late filing of bill of entry; and (b) re-duction in the time taken by cus-toms in according out of charge after registration of goods from 7.74 hours in January, 2017 to 1.89 hours in July, 2017. This reduction is attributable to DPD wherein out of charge is given promptly upon verification of minimal details. The release time comparison for DPD cli-ents having RMS facilitated bills of entry is shown below.
The time release for DPD clients under RMS facilitated category has remained more or less around 76 hours. Howev-er, in January, 2017, in respect of 41.1% of DPD bills of entry release time was less than 72 hours. In July-2017, this per-centage declined slightly to 40.3%. However, considering that the number of bills of entry filed have increased in July as compared to January, a great-er numbgreat-er of bills of entry wgreat-ere cleared within 72 hours in July as compared to January. It is further observed that in July, 90% of such cargo was cleared in 18.4% faster time as com-pared to January, 2017.
Thus, it is evident that all stakeholders reap the benefits of significantly reduced time re-lease in cases where the bills of entries are filed in advance since the time release in case of such advance bills of entry
is 47.5% lower than normal bills of entry. Moreover, if the importer avails the benefit of DPD facility the time release of its consignments will be the lowest among the categories tabulated above.